Statement of John D. Graham

STATEMENT OF JOHN D. GRAHAM, PH.D.
ADMINISTRATOR
OFFICE OF INFORMATION AND REGULATORY AFFAIRS
OFFICE OF MANAGEMENT AND BUDGET
EXECUTIVE OFFICE OF THE PRESIDENT OF THE UNITED STATES

BEFORE
THE
COMMITTEE ON GOVERNMENT REFORM
UNITED STATES HOUSE OF REPRESENTATIVES

July 22, 2003

Good morning, Mr. Chairman, and Members of this Committee. I am John D.
Graham, Ph.D., Administrator, Office of Information and Regulatory Affairs
(OIRA), Office of Management and Budget. Thank you providing me with this
opportunity to share our views on H.R. 2432, the “Paperwork and Regulatory
Improvements Act of 2003.” This bill has stimulated a significant
amount of thought and discussion within OIRA about interests we obviously
share with this Committee. We endorse the bill’s underlying goal of
reducing the burdens that the Federal government imposes on the regulated
public. While we have a number of concerns with the bill that prevent us
from supporting it in its current form, I am hopeful that together we can
use it as a starting point for improving regulatory policy.

While I would like to devote the bulk of my remarks to the bill’s
provisions on regulatory accounting and OIRA staffing, I would first like
to address briefly the other two major provisions. Section 4 would repeal
the exemptions contained in the Farm Security and Rural Investment Act of
2002 from various paperwork review and regulatory due process requirements.
OIRA strongly supports this provision. We would simply recommend that the
Section 4 make this repeal effective six months after enactment, so that
the Department of Agriculture has sufficient time to comply with paperwork
and regulatory requirements. Section 5 would make permanent the authorization
for the General Accounting Office (GAO) to respond to congressional requests
for independent evaluations of selective economically significant rules
proposed or issued by Federal agencies. Since this provision concerns internal
Legislative Branch operations, OIRA chooses not to take a position. We would
urge the Committee, however, to consider whether GAO or the Congressional
Budget Office is the most appropriate entity to be given this responsibility.

Improving Regulatory Accounting

Section 6 of HR 2432 has four provisions aimed at improving OMB’s
annual regulatory accounting statement. Although we support improvements
in regulatory accounting, we have concerns about these four provisions as
well as some suggestions.

1. Should All Federal Rules and Paperwork Requirements
Be Analyzed?

The provision in Section 6(a) would require that OMB require each agency
to submit to OMB an estimate of the “total annual costs and benefits
of Federal rules and paperwork...for the agency in the aggregate; and...for
each agency program.” This requirement is apparently based on Finding
(7) that OMB “does not require agencies to submit estimates on costs
and benefits of agency rules and paperwork” which OMB “needs
… to help prepare the annual accounting statement” under section
624 of the Treasury and General Government Appropriations Act, 2001, also
known as the Regulatory Right to Know Act. This finding is not entirely
accurate. Beginning in 1981, Executive Order 12291 and in 1993 E.O. 12866
have required agencies to submit to OMB estimates of the costs and benefits
of their major regulatory actions, defined generally as rules with impacts
on the economy of $100 million or more. OMB has used these data to prepare
its annual accounting of the costs and benefits of Federal regulations since
1997.

If Section 6(a) is intended to require an estimation of the costs and benefits
of all existing rules and paperwork requirements, this provision is not
workable. It would require OMB and agencies to estimate every year
the costs and benefits of all Federal rules, including those adopted
10, 40 and 100 years ago that are still in effect today. (From 1980 and
2003 alone, over 113,000 final regulations were issued by Federal agencies.)
Although it is feasible for OMB and agencies to assemble cost and benefit
information for major rules adopted over the last ten years, it is not feasible
to estimate reliably the costs and benefits of non-major rules—which
were not subjected to such analysis when adopted—and major rules adopted
more than ten years ago, since the pre-regulation estimates are no longer
valid. Our 2003 draft report provided estimates of the costs and benefits
of regulations in the aggregate, by program, and for major rules over the
period October 1, 1992 to September 30, 2002. Each year in the future, OIRA
plans to provide cost-benefit data for the preceding ten years.

Agencies do not generally submit estimates of costs and benefits of non-major
rules nor do independent agencies submit such data to OMB. If this provision
is intended to require executive branch agencies to produce cost-benefit
information for non-major rules and independent agencies to begin to provide
this information for all their rules, then OMB could not support such a
requirement. Requiring benefits and costs of all rules and all paperwork
to be quantified every year would be a massive, unjustified paperwork requirement.
This could compel agencies to collect massive amounts of new information
from regulated entities to support these new estimates, inadvertently creating
one of the larger new paperwork burdens in recent history.

The fact that attempts to estimate the aggregate costs of regulations have
been made in the past, such as the Crain and Hopkins estimate of $843 billion
mentioned in Finding 5, is not an indication that such estimates are appropriate
or accurate enough for regulatory accounting. Although the Crain and Hopkins
estimate is the best available for its purpose, it is a rough indicator
of regulatory activity, best viewed as an overall measure of the magnitude
of the overall impact of regulatory activity on the macro economy. The estimate,
which was produced in 2001 under contract for the Office of Advocacy of
the Small Business Administration, is based on a previous estimate by Hopkins
done in 1995, which itself was based on summary estimates done in 1991 and
earlier, as far back as the 1970s. The underlying studies were mainly done
by academics using a variety of techniques, some peer reviewed and some
not. Most importantly, they were based on data collected ten, twenty, and
even thirty years ago. Much has changed in those years and those estimates
may no longer be sufficiently accurate or appropriate for an official accounting
statement. Moreover, the cost estimates used in these aggregate estimates
combine diverse types of regulations, including financial, communications,
and environmental, some of which impose real costs and others that cause
mainly transfers of income from one group to another. Information by agency
and by program is spotty and benefit information is nonexistent. These estimates
might not pass OMB’s information quality guidelines. In particular,
many of the studies they relied upon for these aggregate estimates are not
sufficiently transparent about the data and methods to facilitate the reproducibility
of the information by qualified third parties. That is why we have opted
in the most recent Reports to Congress to report just the costs and benefits
of major regulations prepared by agencies and reviewed by OMB over the last
ten years.

Finally, even if the hundreds of agency analysts could generate the aggregate
estimates of the costs and benefits of the over 113,000 final rules that
have been issued since 1980, OIRA would be unable to read and evaluate them,
given our current staffing level. Our concern about Section 6(a) would be
greatly reduced if it were amended to say that agencies would provide the
data “to the extent feasible,” to reflect the instruction to
OMB in Section 624(a)(1) of P.L. 106-554.

2. Should a Seven-Year Time Series Be Specified?

Section 6(b) would require that the accounting statement cover the same
seven-year period covered by the Budget. We question the utility of providing
this information over the seven-year budget cycle. All future costs and
benefits must be presented and seven years is usually not a long enough
time horizon. This points out a major difference as to how budgetary information
is presented compared to benefit-cost information. Reducing the utility
of benefit-cost information by forcing it into this budgetary framework
is not the solution. OMB believes this provision would be improved if it
were amended to say that OMB’s preparation of the statement be done
“consistent with the information-quality law” and “to
the extent feasible.” The cost-benefit information should be presented
in annualized terms, with an indication of the appropriate time horizon.

3. Should the Accounting Statement Be “Part of the
Budget?”

Section 6(c) would require the integration of OMB’s accounting statement
and report into the President’s Budget. OMB believes that the accounting
statement and report should continue to be transmitted “with”
the President’s Budget, not “as part of the budget” (as
would be required by Section 6(c)). If the accounting statement and report
are to be submitted as part of the budget, such a change would significantly
increase the workload burden of preparing the President’s Budget documents
without necessarily improving the quality of the report. Moreover, given
that (1) OMB is currently required to provide for peer review and public
comment on a draft accounting statement and (2) OMB does not believe
it would be appropriate to submit a draft accounting statement and report
with the President’s Budget, OMB would have to submit cost-benefit
data for the past fiscal year, not the fiscal year for which the President’s
Budget is submitted.

OMB believes it could be feasible to issue a separate volume with the budget
that contains the final regulatory accounting report and perhaps some related
budget information for comparison purposes. A separate volume might also
permit adequate presentation of intangible costs and benefits. Intangible
values such as fairness, ecology, privacy, and civil rights are not easily
measured. These considerations might receive less attention than the reported
quantitative information about costs and benefits, if the information is
in summary form for a long list of programs packed in multiple budget documents.

4. Should We Undertake Pilot Tests of Regulatory Budgeting?

Section 6(d) contains the proposed pilot tests of regulatory budgeting.
This is an innovative provision that, with proper refinement, could prove
to be a helpful step forward in regulatory policy. We suggest the following
refinements or clarifications. First, the pilot projects should be smaller,
covering only NHTSA within DOT and the air office within EPA, because, in
OMB’s judgment, these are the only regulatory entities in the Federal
government that are prepared—based on institutional and technical
capacity—to tackle this ambitious project. As currently written, the
agencies covered (Labor, Transportation and EPA) account for a large proportion
of the total rulemaking activity of the Federal government. That is far
too ambitious for a pilot effort. Moreover, OMB does not have adequate staffing
to accomplish effective oversight of more than two modest pilots. Second,
the provision should clarify that the alternative regulatory budget levels
to be set by OMB (a) are for non-budgetary costs and (b) are hypothetical
and informational in nature and thus do not have legally binding impact.
The language should clarify that agencies are permitted to exceed the alternative
"budget levels" if the agency head determines it is appropriate
to do so or if statutory or other legal requirements for rulemaking compel
the regulatory budget levels to be exceeded. Although we could be supportive
of these pilot projects, we caution the Committee that overly ambitious
language could lead to failure of these projects, which in turn might give
the concept of "regulatory budgeting" a bad name. If the projects
are successful, showing ways to achieve more health and safety protection
at less overall cost, then the pilots may pave the way for more widespread
use of regulatory budgeting throughout the Federal government. The project
is so innovative that we believe it will be closely watched by other Federal
agencies, State and local governments, and foreign governments interested
in regulatory reform.

On regulatory budgeting, I would like to conclude with a few observations
about why the Committee should be cautious about fostering direct comparisons
between budgetary outlays and non-budgetary, regulatory costs and benefits.
First, unlike the fiscal budget, an audit to determine whether regulatory
costs or benefits are accurate is not feasible. It is sometimes feasible
to perform ex post evaluations of the costs and benefits of rules, and compare
these ex post amounts to the pre-regulation estimates, but even these studies
will typically provide only rough estimates. For this reason, regulatory
costs and benefits are inherently more speculative than budgetary outlays.
Second, some advocates of regulatory budgeting confuse the notion of accounting
costs (e.g., audited budgetary expenditures) with social opportunity costs
and hedonic costs, which are the foundation of regulatory costs. Social
opportunity costs include consumer and producer surpluses as well as actual
expenditures (price times quantity), and are therefore conceptually different
from budgetary outlays or expenditures. Moreover, hedonic costs (e.g., the
economic value of extra travel time, increased safety, and higher quality
products) are measured and expressed in dollar units but they are not "expenditures"
in a way that is directly comparable to budgetary expenditures. Third, while
there is no such thing as an “intangible” or unquantifiable
budgetary expenditure, some of the most important regulatory costs and benefits
are intangible or very difficult to quantify (e.g., privacy, civil rights
and some ecological amenities). Fourth, while the notion of regulatory "benefit"
is well defined and often quantifiable, the budgetary process does not produce
information on "benefits" for budgeted activities. Performance
measurement in budgeting is on the rise but many performance measures are
not economic in the same way that regulatory benefits are economic in nature.
For these reasons and others, the Committee should be careful about suggesting
that budgetary outlays and regulatory costs and benefits can be directly
compared. Instead, regulatory cost-benefit information should be considered
another piece of performance information that the budgetary process might
consider. Valid benefit-cost information is an important consideration in
budgeting for regulatory programs and this use of such information is certainly
consistent with OMB’s implementation of the Government Performance
and Results Act (GPRA).

We also have concerns about two of the subsections that Section 6(d) would
add to Chapter 11 of Title 31 of the U.S. Code. The new Subsection 1120(c)
would require OMB to “include, as an alternative budget presentation
in the budget submitted under section 1105 for fiscal year 2007, the regulatory
budgets of the designated agencies for that fiscal year.” The new
Subsection 1120(d)(3) would require OMB to submit a report on the pilot
projects to the President and to Congress that would “recommend whether
legislation requiring regulatory budgets should be proposed and the general
provisions of any legislation.” Our view is that these provisions
are inconsistent with the Recommendations Clause of the Constitution, which
gives the President the authority to submit for the consideration of Congress
such measures as the President judges necessary or appropriate. We therefore
recommend that these two provisions be amended to require the submission
of recommendations to Congress only “to the extent the President judges
necessary or appropriate.”

We are very pleased that the committee is interested in regulatory accounting
and budgeting, and we believe that we can work with you to make significant
advances in this area. Specifically, I would propose that the committee
give strong consideration to the following three issues, which I believe
are central to meeting the challenge of improving the accounting and budgeting
of regulatory costs and benefits. First, we must explore ways to measure
those costs and benefits that are most difficult to quantify. Second, given
the uncertainty of some agency estimates, agencies should be encouraged
to base their cost-benefit analyses on valid scientific data and principles.
Finally, I would urge the committee to consider the impact of more rigorous
regulatory accounting and budgeting on the analytic resources in the agencies
and OMB.

Before discussing Section 3 of H.R. 2432, I would like to respond to Finding
1 in Section 2, which asserts that “OIRA's principal responsibility
is to reduce the paperwork burden on the public that results from the collection
of information by or for the Federal government.” When OIRA was created
in 1980, it was accurate to say that OIRA's principal responsibility was
paperwork review. However, OIRA has changed dramatically since 1980 as we
have assumed additional responsibilities, such as regulatory review, information
technology, information-quality oversight and statistical policy. During
the same period, the number of full-time equivalent staff at OIRA declined
steadily from a peak of 90 in 1980 to 47 in 2000, with a modest increase
to 55 in 2003. Moreover, although reduction of paperwork burden is one of
the primary objectives of the Paperwork Reduction Act of 1995 (PRA), another
priority of the Act is to “ensure the greatest possible public benefit
from and maximize the utility of” information collected by government
in support of vital government functions. Both objectives of the PRA are
important and they should not be considered in isolation of each other.
Thus, we respectfully suggest that Finding 1 in Section 2 be revised to
provide an up-to-date description of OIRA.

The requirement in Section 3 that OIRA devote at least two full-time staff
to reducing tax-related paperwork burden is based on this finding in Section
2. It is also based on a perception that, since approximately 80 percent
of overall paperwork burden by Federal agencies is imposed by the Internal
Revenue Service (IRS), OIRA should have a substantial staff investment in
review of IRS paperwork. While the 80 percent figure is roughly accurate,
we believe this figure does not necessarily justify an increase in OIRA
staff investment in IRS paperwork reviews. There are good reasons why OIRA
does not make substantial staff investments in IRS paperwork review:

1. OIRA’s staffing allocations reflect both the
full range of OIRA’s agency oversight responsibilities and OMB’s
historical deference to Treasury on tax policy and regulatory matters.

2. Most of the IRS paperwork burden is rooted in the
Tax Code, and therefore beyond IRS’ discretion to control.

3. There have been continued successes in the IRS-initiated
efforts to reduce unnecessary paperwork burdens and IRS has perhaps the
largest and most proficient paperwork-review office in the Federal government.
Thus IRS has seldom been found to be in violation of the PRA.

4. Where OIRA has been effective in assisting IRS is
in improved measurement of paperwork burden, an important analytical step
toward performance measurement under the PRA and the GPRA.

I would like to elaborate on each of these four points.

1. Rationale for OIRA's Staffing Allocation to IRS

With our limited number of personnel (55 FTEs), OIRA must make staffing
allocations that cover all agencies of the Federal government in five functional
areas: regulatory review, paperwork review, information technology, information
quality and statistical policy. Two of OIRA's four branches, comprised of
22 full-time analysts, are primarily responsible for the regulatory and
paperwork reviews of all Federal agencies—including HHS, Labor, EPA,
Transportation, Interior, Agriculture, as well as the new Department of
Homeland Security and Treasury. The President expects thorough OMB oversight
of all of these agencies, so these 22 full-time analysts are spread
across dozens of large and small Federal agencies. In addition, these analysts
devote their time to many other activities, including the annual development
of the report to Congress on the costs and benefits of regulation, the report
to Congress on the Unfunded Mandates Reform Act, and the Information Collection
Budget.

Since some studies indicate that regulation is vastly more costly to the
public than paperwork requirements per se—and a significant amount
of paperwork not imposed by legislation is imposed by regulation—the
allocation of these 22 full-time analysts is weighted toward regulatory
review. (Keep in mind that good regulatory review also reduces paperwork
burden, an activity that we undertake in close collaboration with the Advocacy
Office of the Small Business Administration.) Congress recognized the importance
of Federal regulation in the Regulatory Right to Know Act, which is the
foundation of OIRA’s annual report to Congress on the costs and benefits
of Federal regulation. In the President's March 2002 call for public nominations
of reforms to rules, guidance documents and paperwork, the vast majority
of public interest—including small business interest—was in
reform of rules and guidance documents. When paperwork burdens were nominated
for scrutiny, they tended to be paperwork burdens created by regulation.

When I assumed the leadership of OIRA two years ago, there was one “desk
officer” devoted to IRS. I understand that this staffing level for
IRS paperwork has remained relatively constant since the Paperwork Reduction
Act was first enacted in 1980. During the last year, in response to congressional
interest, we increased senior-level support to that desk officer to better
determine whether more OIRA staffing could produce less paperwork burden
on small businesses and the general public. I must say that I have not been
convinced that an increase in the number of IRS desk officers at OMB is
a cost-effective use of scarce OIRA resources.

First, IRS and OMB have acquired over 20 years of experience under the PRA.
Many of the more burdensome IRS information collections (e.g., high-volume
tax forms that are based on statutory requirements) have been reviewed by
IRS and OMB on a recurring basis and the issues concerning them have been
resolved in previous reviews. When Congress changes the Tax Code, the paperwork
burdens change but in most cases the discretion at IRS and OIRA to influence
that burden is limited.

Second, there has been a historical agreement between OMB and Treasury that
provides Treasury a high degree of autonomy on tax and revenue regulatory
matters. Under every President since Jimmy Carter, OMB has not, as a routine
matter, reviewed IRS interpretive regulations. After President Reagan issued
EO 12291 in February 1981, Treasury and OMB entered into a “Memorandum
of Agreement” that exempted from OIRA review all IRS interpretative
regulations. After President Clinton issued EO 12866 on September 30, 1993,
the OIRA Administrator informed Treasury that "simply stated, we are
continuing the Treasury Department's current exemptions from regulatory
review...” This Administration considered early on whether to change
this relationship and a decision was made—above my pay grade and for
good reasons—to retain the historical OMB-Treasury relationship.

It is important to understand the historical rationale for OMB deference
to Treasury. First, OMB’s predecessor, the Bureau of the Budget, was
once part of Treasury. When President Roosevelt moved the Bureau out of
Treasury in 1939 and placed it in the Executive Office of the President,
the staff expertise on tax policy and paperwork review remained with Treasury,
where it continues to vastly exceed that of OMB. Considering specialization
of labor, OMB staff investment in tax expertise is not very sensible. Second,
the Watergate years taught us the dangers of politicizing the process of
tax administration. By deferring to Treasury, each Administration since
Jimmy Carter’s has insulated itself from the charge that it was using
White House review of the IRS for political purposes.

Taking all of this into consideration, I believe that any rational OIRA
Administrator would not be inclined to make review of IRS paperwork a more
significant staffing priority. An understanding of how Congress creates
paperwork burden through the Tax Code further underscores this conclusion.

2. The Tax Code and IRS Burden

In evaluating IRS’s record on burden reduction,
it is important to note the challenge IRS faces in administering the Tax
Code. To a greater extent than for other agencies and programs, IRS paperwork
burden is driven by a statute (the Tax Code), and in particular the complexities
of the Code. To ensure taxpayer compliance with our tax laws, IRS must
collect a tremendous amount of information. This task is complicated by
a massive, complex Tax Code that is subject to continuous revision. In
the 15 years following the 1986 overhaul of the Code, Congress passed
84 tax laws. These laws required IRS to create and/or revise reporting
and recordkeeping requirements, which in turn increased taxpayer burden.
The Internal Revenue Service also had to make several changes to the 1040
schedules to implement the Economic Growth and Tax Relief Reconciliation
Act of 2001. These statutorily driven revisions increased the burden on
taxpayers by 47 million hours. Moreover, there are other factors totally
outside the control of IRS—most notably increases in the number
of tax filings due to economic and population growth over the years—that
increase the aggregate IRS burden hours but not—and this is important—the
average burden on individual taxpayers.

Sometimes it is mandated reductions in tax liability that result
in more paperwork burden. Consider, for example, the recently enacted tax
benefit that allows teachers to subtract up to $250 from their taxable income
for the purchase of classroom supplies. To implement this tax benefit, the
IRS had to provide significant explanation on the Form 1040 about eligibility
requirements to claim the tax benefit. Eligible taxpayers must fill out
a separate worksheet to compute the amount, up to $250, that they may claim.
This burden is necessary for IRS to determine if a taxpayer is claiming
the benefit correctly. We reviewed IRS’ work and did not find any
unnecessary burden.

While we must ensure that paperwork burden is not unnecessarily increased
in order to implement tax changes, it remains the case that taxpayers probably
consider it a good trade-off to incur some additional paperwork burden in
return for their taxes going down. OMB is committed to continued efforts
to reduce paperwork burden responsibly—form by form, regulatory requirement
by regulatory requirement. However, setting arbitrary staffing goals that
have no analytic basis does not make sense.

3. Recent Efforts to Reduce IRS Paperwork Burden

Despite the challenges it faces in administering the Tax
Code, IRS is making progress. As we reported in the recently released
Information Collection Budget, in FY 2002 the Treasury Department achieved
a net program change reduction due to agency actions of 9.51 million hours,
largely as a result of actions within the control of IRS (i.e., changes
in paperwork not due to new statutory requirements or violations of the
PRA). After years of reporting increases, we are encouraged by this result
and fully intend to build on this important accomplishment by achieving
further reductions in the future. Several notable examples of such IRS
actions include:

Revisions
made to Form 6251 – This form is used to implement the requirements
of the Alternative Minimum Tax for individuals. IRS eliminated several
lines and made other simplifying changes that resulted in a change in
taxpayer burden of 5.5 million hours.

Changes
to Form 1040-EZ – This form is used by individuals who are single
or joint filers with no dependents. IRS reduced taxpayer burden by 4.3
million hours by deleting several worksheets and a number of lines to
this form.

Changes made to Schedule D of Form 1040 – This form is used by
individual taxpayers to report taxable income and calculate their correct
tax liability. It was revised and simplified to make it easier for taxpayers
to compute their capital gains and losses, resulting in a reduction
of 2.9 million burden hours.

Treasury and IRS do a much better job than most agencies of carrying out
their responsibilities under the Paperwork Reduction Act. IRS does not commit
PRA violations and it has initiatives for reviewing its collections to identify
opportunities for burden reduction. Few other agencies can say the same
with equal strength. Because Treasury and IRS dedicate significant resources
to paperwork review, and can demonstrate accomplishments in this area, OIRA
does not have to dedicate additional resources to reviewing IRS paperwork
to ensure that a careful PRA review is conducted.

4. Measuring IRS Burden

In recognizing that the Tax Code hinders IRS’s ability to reduce taxpayer
reporting burden, OMB has worked with IRS and Treasury to replace its current
burden estimation methodology with a new measure of compliance burden. This
revised measure will provide policymakers with a tool to assess the effects
of legislative proposals to create and revise statutory provisions on the
taxpayer burden before they are enacted. The specific goals of
the new methodology include:

providing a tool to reduce compliance burden during the development
and analysis of legislative and administrative proposals; and

providing a tool to explain current levels of taxpayer burdens and the
changes in those burdens due to administrative or statutory changes.

We believe that the capability of the new model to predict
changes in burden due to changes in tax law—as well as changes in
IRS tax administration—will allow OMB, Treasury, IRS, and Congress
to work together to achieve tax policy objectives in a manner that minimizes
taxpayer burden, consistent with the effective and fair collection of
needed tax revenue.

In summary, OIRA has decided that its overall performance
would not improve if OIRA reassigned its staff from other responsibilities
to reviewing IRS paperwork. Admittedly, this is a judgment call. However,
this is a judgment call that I as a manager must make in deciding how
OIRA can best serve the President and carry out our numerous statutory
responsibilities. The bottom line is that OIRA needs the “freedom
to manage” and the mandated staffing in Section 3 represents an
unprecedented and unwarranted intrusion on the ability of the President
to manage his office.

In conclusion, the Administration recommends against enactment
of this bill in its current form, but we would be prepared to work with
you to fashion paperwork and regulatory improvement legislation that we
could all support. That concludes my prepared testimony. If you have any
questions, I would be happy to answer them.